Posted October 29, 2014

INGAA and its members have worked with EPA on greenhouse gas (GHG) projects dating back to the Gas Research Institute (GRI) project with EPA in the early 1990s that estimated methane emissions from natural gas systems. The GRI-EPA Reports2 remain a seminal reference for GHG estimates for natural gas operations two decades after its completion. Over the past five years, INGAA has worked with EPA on the Greenhouse Gas Reporting Program (GHGRP)3 and the Subpart W rulemakings in an effort to improve natural gas transmission and storage (T&S) national inventories and emission estimates. INGAA and its members have demonstrated their commitment and cooperation in improving GHG emission inventories and reducing methane emissions.

The goal of the STAR Gold Program should be to recognize facility and company achievements in voluntarily reducing methane emissions. INGAA supports the general objective of the STAR Gold Program to reward companies that achieve voluntary methane reductions from primary GHG sources.

However, INGAA has significant concerns with the STAR Gold Program, as currently proposed. The STAR Gold Program’s Proposed Framework includes emission reduction practices that are inconsistent with past efforts and are not common or cost-effective for T&S operations. INGAA welcomes a program that builds upon the lessons learned over the last two decades regarding the primary T&S GHG sources and best practices for reducing emissions. INGAA cannot support the STAR Gold Program unless it includes the demonstrated and established methods that achieve reductions from primary T&S methane emission sources. INGAA’s specific concerns are as follows:

The Proposed Framework does not rely on established and proven methods from the EPA STAR program.
EPA’s Proposed Framework is ineffective since it applies the same approaches across all sectors.
The STAR Gold Program should recognize that the vast majority of methane emissions come from a small number of sources.

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